Epstein Secrets

DAD COLEMAN, ESQUIRE For Jeffrey Epstein: ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Ave. South, Suite 1400 West Palm Beach, FL 33401 By JACK A. GOLDBERGER, ESQUIRE For Jeffrey Epstein: DARREN K. INDYKE, PLLC 575 Lexington Avenue New York, NY 10022 By DARREN K. INDYKE, ESQUIRE Palm Beach Reporting

4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 answers that are unverified. From a telephone conversation that Mr. Goldberger, Mr. Scarola and Mr. Edwards and I had regarding the logistics of trying to deal with the stay or a motion and how we were going to go forward, th

ng this 518 Southern And again, the was quoted by the Florida Supreme Court in 1994 in the Southern Bell Telephone and Telegraph Company versus Deason. Frankly, Judge, if the Court wants me to go through the other objections that were raised in deposition that have no basis in law in a depositio

akes Blvd., West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, P.A., 250 A

y of January, 2012 to: Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, P.A., 250 Australian Ave. South, Suite 1400, West Palm Beach, FL 33401-5012; and Marc S. Nurik, Esq., Law Offi

f whether they pertain to confidential communications between attorney and client. Fla. R. Civ. P. 1.280(b)(2). See Southern Bell Tel. & TeL Co. v. Deason, 632 So. 2d 1377 (Fla. 1994). Work product is a qualified immunity from discovery. See DeBartolo-Aventura, Inc. v. Hernandez, 638 So. 2d 988 (Fla.

so those questions are still objected to, unresolved. So, we'll stoppage We will go from there, see what happens. Id. at page 98; lines 13-18. MR. GOLDBERGER: Well, wait a minute. Just one thing... So if we had asked the same questions, he would have raised the same objections, so not only are we going t

e the same or similar information is available through ordinary investigative techniques and discovery procedures.'" Southern Bell TeL & TeL Co. v. Deason, 632 So. 2d 1377, 1384 (Fla. 1994). Here, the information sought by Epstein from Edwards in deposition is not "available through ordinary investiga

so those questions are still objected to, unresolved. So, we'll stoppage We will go from there, see what happens. Id. at page 98; lines 13-18. MR. GOLDBERGER: Well, wait a minute. Just one thing... So if we had asked the same questions, he would have raised the same objections, so not only are we going t

ques and 19 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585412 discovery procedures.'" Southern Bell TeL & TeL Co. v. Deason, 632 So. 2d 1377, 1384 (Fla. 1994). Here, the information sought by Epstein from Edwards in deposition is not "available through ordinary investiga